Setting up an Investment Management Firm in the ADGM: A Conversation with Ghassan Zeidan

Abu Dhabi is rapidly solidifying its position as the region’s primary hub for capital, investment, and financial innovation. Within this landscape, the Abu Dhabi Global Market (ADGM) has emerged as the preferred destination for asset and fund managers looking to tap into institutional and sovereign wealth.

In the lead-up to FutureFunds in Abu Dhabi on 28th January, our Editorial Director, Oliver Kirkbright, sat down with Ghassan Zeidan, Founder and CEO of Paragon Consulting Partners, to discuss the tactical requirements for fund managers establishing a presence in the UAE.

Oliver Kirkbright: Ghassan, thank you for joining us. We are seeing a significant influx of financial firms into Abu Dhabi. In your view, why has the ADGM become such a "natural home" for asset and fund managers specifically?

Ghassan Zeidan: It’s a pleasure, Oliver. The draw of the ADGM lies in its unique combination of stability and sophistication. It operates on a direct application of English common law, which provides a high level of comfort for international investors.

Beyond the legal framework, the Financial Services Regulatory Authority (FSRA) has built a very robust regulatory regime. When you combine that with proximity to some of the world’s largest sovereign wealth funds and a competitive tax environment—including a potential 0% corporate tax on qualifying income—it becomes a very compelling strategic choice for those looking to build a scalable global platform.

OK: For a firm looking to make that move, what does the regulatory landscape actually look like? What kind of permissions are we talking about?

GZ: Any firm operating “in or from” the ADGM must obtain a Financial Services Permission (FSP). For investment managers, we generally look at three core activities: Managing Assets, Managing a Collective Investment Fund, or Advising and Arranging Deals.

Most managers fall into Category 3C for asset and fund management, or Category 4 if they are strictly focused on arranging or advisory activities. The capital requirements are then calibrated based on the risk profile of those specific activities.

OK: I think many firms are interested in the "how." Could you walk us through the actual process of gaining authorisation from the FSRA?

GZ: It’s a structured journey, typically following four main stages:

• Initial Engagement: This is where we define the proposed operating model and targeted company strategies. It is vital to engage the ADGM and FSRA early to test the proposed scope.

• The Application Pack: This requires a detailed Regulatory Business Plan. You need to demonstrate your governance structure, risk appetite, and how you’ll align with UAE federal laws regarding AML and sanctions.

• Local Substance: This is a critical point. The FSRA expects genuine decision-making to happen in Abu Dhabi. Key roles like the Senior Executive Officer (SEO) and Compliance Officer (CO) must be UAE residents with the right experience.

• In-Principle Approval: Once the FSRA is satisfied, you receive an "In-Principle Approval" (IPA). This allows you to finalise your incorporation, bank accounts, and office space etc. before the final FSP is granted.

OK: Getting the licence is obviously a milestone, but the work doesn't stop there. What are the ongoing expectations for a firm once they are live?

GZ:  Exactly. Post-licensing is about maintaining high standards of governance and robust operations. Firms are subject to risk-based supervision. This means maintaining regulatory capital buffers, conducting ongoing AML screening, and ensuring an independent internal audit is completed within the first 12 months amongst other obligations. The Board is expected to provide active oversight and show that they are truly overseeing management.

OK: You’ve mentioned that many operational issues only emerge after the licence is granted. How does a firm ensure it stays resilient as it scales?

GZ: Resilience comes from a proactive posture. A successful firm maintains a robust governance structure with clear delegation of authority and accountability. They also need to focus on operational resilience—things like cybersecurity, data protection, and incident response. It’s about building a framework that doesn't just meet the minimum requirements but actually protects the business and enhances investor confidence.

OK: Finally, Ghassan, where does Paragon Consulting Partners fit into this journey for a prospective fund manager?

GZ: We support firms across the entire lifecycle. We help with the initial licence strategy and the development of the Regulatory Business Plan, but we also go much deeper into the implementation. We provide outsourcing services for Governance, Risk Management, Internal Audit, and Cybersecurity. Essentially, we help firms become—and remain—"ADGM-ready" so they can focus on their core mission of managing capital.

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Read the Full Report: For a detailed breakdown of the regulatory requirements and operational frameworks mentioned in this interview, you can access the full technical details outlined by Ghassan Zeidan -> Industry Insights and Trends - Paragon Consulting Partners

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Ghassan Zeidan is Founder and CEO of Paragon Consulting Partners, a specialist regulatory, risk, internal audit and cybersecurity advisory firm serving financial institutions in ADGM and DIFC. Paragon supports asset and fund managers, private capital, wealth managers, insurers and fintechs with outsourcing and advisory mandates.

Drawing on two decades with HSBC, Bank of America, Barclays and EY across London and the GCC, Ghassan leads client delivery and advises boards and executives on risk, regulation, internal audit and governance. He combines deep technical expertise with a commercial lens to design pragmatic governance, risk and control frameworks that enable resilient growth. Ghassan holds an MBA from the University of Oxford and is a certified Financial Risk Manager (FRM) from GARP and Internal Auditor (IACert) from the Chartered Institute of Internal Auditors.

How Paragon Consulting Partners can help: Establishing an investment management firm in the ADGM is a strategic decision that shapes how your firm accesses capital, manages regulatory risk and scales across the region. 

Paragon Consulting Partners supports asset managers, fund managers and investment firms across the full lifecycle of the setup process: from licence strategy and Regulatory Business Plan development, through to the design and implementation of Governance, Risk Management, Internal Audit, Regulatory and Cybersecurity frameworks via our Outsourcing and Advisory services. 

If you are considering establishing, refining or expanding an investment management firm in ADGM, contact Paragon Consulting Partners to discuss how they can help you become fully ADGM-ready